Let's say I spend 10 months working as a regular employee in Czech Republic. Then in November I find a new job in Germany and move to work there. I've spent more than 183 days in Czech Republic so I'm supposed to be a tax resident there in that year. On the other hand I've moved out of the country so my domicile is now in Germany.

Do tax laws in the EU say something about such a situation?

2 Answers 2


The answer is simply no. The EU has extensive rules about import duties (a common tariff) and VAT, some rules about the “social security” system (health insurance, retirement) but almost nothing on income and other taxes. That's an area that has always been politically sensitive and extraordinarily complicated so that very little progress has been made towards harmonization.

EU countries do not even share the same tax year, let alone the same definition of income or the same type of taxes! So there are places where the tax year is distinct from the civil year (e.g. the UK), flat taxes, taxes on income that are really wealth taxes (e.g. “box 3” in the Dutch income tax), you name it.

Many countries will have generally sensible rules (it's seldom as simple as a 183 days threshold), even interpreted in isolation, and many others will have tax treaties to avoid any issues but none of that is guaranteed, even within the EU. So you really should not expect much and really need to look at the specifics of your situation.


There are treaties against double taxation. You spent 183 days in the Czech Republic, and less than 183 days in Germany, therefore for that year you're still a tax resident of the Czech Republic. If you stay in Germany, the next year you'll be a tax resident of Germany.

  • Double taxation treaties don't mean that you can't be tax resident in two countries in one year, just that if you file all the paperwork correctly you will only pay income tax on your money once. Commented Jan 13, 2018 at 22:16
  • No, you can't be a tax resident of two countries who signed a treaty against double taxation. That's the whole point of the treaty. The tax residency dictated by the treaty determines where you'll pay your taxes. I've literally done that within the EU, but feel free to downvote and argue with me.
    – Teflon Don
    Commented Jan 13, 2018 at 22:54
  • "To determine where you should pay your taxes it is important to establish in which country you are tax resident. ... The tax treaty normally contains rules to establish residence in cases where two countries regard someone as resident." ec.europa.eu/taxation_customs/frequently-asked-questions/…
    – Teflon Don
    Commented Jan 13, 2018 at 22:58
  • "You live in Germany for no more than 6 months - You are not considered tax resident, and pay tax only on income earned in Germany (limited tax liability)." europa.eu/youreurope/citizens/work/taxes/income-taxes-abroad/… "Living in the Czech Republic for at least 6 months in the (current) tax year? You are usually considered as resident for tax purposes and have to pay tax on your worldwide income there." europa.eu/youreurope/citizens/work/taxes/income-taxes-abroad/…
    – Teflon Don
    Commented Jan 13, 2018 at 23:32
  • worldwide-tax.com/czech/cze_double.asp ec.europa.eu/taxation_customs/individuals/personal-taxation/… Therefore according to the treaty, since you're a tax resident of the Czech Republic for that year, you don't pay any tax in Germany for that year, instead you tax everything, even the income from Germany, in the Czech Republic.
    – Teflon Don
    Commented Jan 13, 2018 at 23:36

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